Indiana Proof-of-Citizenship Voter Law Survives Legal Challenge as Judge Dismisses Suit on Procedural Grounds

A federal judge dismissed Indiana voting rights groups' lawsuit on procedural grounds, leaving in place laws that have canceled or rejected the voter registrations of about 62% of flagged naturalized citizens — with November midterms approaching.
Federal judge dismisses lawsuit challenging Indiana’s new proof of citizenship requirement

A federal judge has thrown out a voting rights lawsuit challenging Indiana’s proof-of-citizenship voter registration laws, finding that the advocacy groups that brought the case lacked legal standing to sue — leaving the laws in force with November midterm elections weeks away.

U.S. District Judge Matthew Brookman, a nominee of former President Joe Biden, dismissed the suit Thursday without ruling on whether the laws are constitutional. He gave the plaintiffs 28 days to file an amended complaint, according to Democracy Docket, a voting-rights organization founded by Democratic lawyer Marc Elias that tracked the case.

The four plaintiff organizations — the League of Women Voters of Indiana, Common Cause Indiana, Hoosier Asian American Power and Exodus Refugee Immigration — sued Indiana Secretary of State Diego Morales, a Republican, over two state laws that require certain voters to produce documentary proof of citizenship or lose their registration. Both laws took effect July 1, 2025.

The statutes target voters who hold, or have previously held, temporary driver’s licenses or identification cards — credentials issued to people who were not yet citizens when they first applied. Temporary credentials can remain valid for up to six years even if a person’s immigration status changes, meaning the database flags many people who have since become citizens.

Indiana Public Media reported that state officials identified 3,234 people for scrutiny under the statutes. Of those whose cases were completed, 977 provided acceptable proof of citizenship. But 644 prospective voters were rejected and 981 existing voters had their registrations canceled — about 62% of the 2,602 people processed. That analysis was conducted by Michael McDonald, a professor of political science at the University of Florida. The figures include people who never responded to notices, even when the U.S. Postal Service returned those notices as undeliverable.

Plaintiff organizations say the laws create a two-tiered system that singles out naturalized citizens who have already sworn to their citizenship under penalty of perjury when registering — an oath that natural-born citizens also sign, but without the additional documentary hurdle. “Making thousands of Hoosiers who are U.S. citizens jump through extra hoops to vote because they are naturalized will result in many of those Hoosiers refusing to vote,” Julia Vaughn, executive director of Common Cause Indiana, said in a statement from the plaintiffs’ legal team.

Brookman’s standing ruling was narrow. He noted it was “curious” that the suit included no individual plaintiffs directly harmed by the law, even as the organizations submitted court declarations from four affected voters. He dismissed the case without reaching the constitutional or statutory questions the organizations raised — and without touching the preliminary injunction they had sought to pause enforcement before the election.

Among those caught in the system is Charrie Stambaugh, a U.S. citizen for nearly three decades, whose story was reported by Indiana Capital Chronicle and published by WISH-TV. When Stambaugh visited a Bureau of Motor Vehicles office in October 2025 to upgrade to a Real ID, her Certificate of Citizenship triggered a database check that went unresolved during a federal system outage. Her registration was quietly canceled. She found out months later only after seeing a Facebook post urging Hoosiers to check their status.

“No eligible voter should have to discover by chance that their voter registration is no longer active,” Stambaugh said. “I worry about people that show up on Election Day … and they get turned away.”

The BMV sends its temporary-status credential list to the state Election Division every night; names are added to it but never removed, even after citizenship is confirmed. The scope of the state’s citizenship screening extends further still: Indiana’s attorney general and secretary of state sent the names of 585,774 Hoosier voters to U.S. Citizenship and Immigration Services for federal verification in October 2024, weeks before the presidential election, according to the Indiana Citizen, a nonpartisan nonprofit news organization. A state court has since ruled that list can remain secret.

A federal bill that would impose similar proof-of-citizenship requirements on voter registration nationwide — the Safeguard American Voter Eligibility Act — passed the U.S. House in February but has not cleared the Senate.